Assess whether comparative files show second-review bias from underwriting

SITUATION Model-risk partner for credit scoring is responsible for comparative files show second-review in a small-business desk using a new vendor score, using underwriting exception log by branch as the only working extract. A SPCP that originated almost no loans to the intended class is what reset the timeline for this Fair Lending Pricing and Credit Limits file.

DECISION Model-risk partner for credit scoring in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Underwriting exception log by branch reads as Remove access or reverse the item once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population. 2. Underwriting exception log by branch is closer to Temporary compensating control after a SPCP that originated almost no loans to the intended class; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in underwriting exception log by branch for model-risk partner for credit scoring in a small-business desk using a new vendor score. 4. Underwriting exception log by branch is missing the fact model-risk partner for credit scoring needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from underwriting exception log by branch. 2. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 3. Match the adverse-action language to the facts in underwriting exception log by branch. 4. For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a SPCP that originated almost no loans to the intended class and write the one fact that would move comparative files show second-review for model-risk partner for credit scoring.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (underwriting exception log by branch after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option underwriting exception log by branch can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a small-business desk using a new vendor score.